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Stephen A. Beck

About this Webinar

Overview

Partnership combinations and divisions are widely viewed as simple transactions that do not give rise to material income tax consequences. In reality, however, the income tax rules governing these transactions can be very complicated and lead to surprising results. This presentation will first discuss the manner in which partnership combinations are treated under the federal income tax rules and the various income tax effects that can result from such treatment. Next, this presentation will discuss the various income tax rules that must be analyzed to determine whether a partnership division will cause current federal income tax effects.

Key Topics

Treas. Reg. §1.708-1(c) Classification of Partnership Mergers.

Potential Collateral Effects of Partnership Mergers (e.g., Reverse I.R.C. §704(c) Allocations; Mandatory I.R.C. §743(b) Basis Adjustment?)

Treas. Reg. §1.708-1(d) Classification of Partnership Divisions.

Potential Gain Recognition from Partnership Divisions (e.g., I.R.C. §751(b); Mixing Bowl Rules; Disguised Sale Rules; I.R.C. §731)

Details

Course Level: Intermediate
Prerequisite:
Partnership Tax course recommended
Cost: Free

CPE and MCLE Credit Info:
Course Number: 174233383
CPE Credit: 1.20 Hrs.
MCLE Credit: 1.00 Hr.

CFP Credit Info:
CFP Course Number: 3469129 (Credit Pending)
CFP Credit: 1.00 Hr.

About the Speaker

Stephen A. Beck, J.D., LL.M.

Partner

Mr. Beck is a Board Certified tax attorney who provides Federal income tax and Texas franchise and sales tax advice to businesses of all types and sizes, including Subchapter C corporations, Subchapter S corporations, partnerships, limited liability companies, and entities disregarded for Federal income tax purposes. He advises on tax issues arising during all phases of business operations, including formation, restructuring of ownership interests, acquisitions, dispositions, mergers, consolidations, liquidations, international transactions, issuance of deferred and equity compensation, and business succession planning. He represents businesses and entrepreneurs in a broad range of industries, including professional services, manufacturing, technology, oil and gas, and real estate. He also advises tax-exempt organizations under Section 501 of the Internal Revenue Code.

Mr. Beck also represents individuals, businesses, and estates in tax related controversy matters, including Internal Revenue Service audits, appeals, and litigation in Federal courts, including the U.S. Tax Court and Fifth Circuit Court of Appeals. He also represents taxpayers in franchise and sales tax disputes with the Texas Comptroller of Public Accounts.

Mr. Beck is Board Certified in Tax Law by the Texas Board of Legal Specialization. He has served as an adjunct law professor at Southern Methodist University Dedman School of Law, where he taught Corporate Income Taxation. He has also served as the Chairperson of the Dallas Bar Association’s Peer Assistance Committee and Co-Chair of the Texas Bar Tax Section Partnership and Real Estate Committee. Mr. Beck was admitted to practice in Texas in 1998 and the District of Columbia in 2000.

Read his full bio here. You can contact Mr. Beck at 214-744-3700 or by email at sbeck@meadowscollier.com.